S. Sethuraman vs R. Venkataraman & Ors

The Supreme Court held that promotions to the post of Headmaster in Tamil Nadu schools are governed by the Tamil Nadu Recognised Private Schools (Regulation) Act, 1973 and the Tamil Nadu Private Schools (Regulation) Rules, 1974, specifically Rule 15(4), which mandates that promotions be based on merit and ability, with seniority considered only when merit is equal. The Court upheld the Managing Committee's decision to promote the appellant over the respondent based on a comparative evaluation of merit, despite the respondent's prior position as Secretary in another school. The appeal against the High Court's decision was dismissed, affirming the appointment of the appellant as Headmaster.